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Privacy Policy for Cheltenham Guardians Safeguarding Team

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The Cheltenham Guardians Safeguarding Team (“we,” “us,” or “our”) is committed to protecting your privacy and ensuring compliance with the General Data Protection Regulation (GDPR), the UK GDPR, and other applicable data protection laws. This Privacy Policy explains how we collect, use, disclose, and protect your personal data when you visit our website www.cheltenhamguardians.org or interact with our services, including our use of body-worn video (BWV) by volunteers. It also describes how we use cookies and similar technologies on our website.

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1. Who We Are


We are the Cheltenham Guardians Safeguarding Team, a non-profit organisation dedicated to safeguarding vulnerable women and girls in the Cheltenham community. Our contact details are:

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For GDPR purposes, we are the Data Controller responsible for the personal data we collect and process.

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2. What Personal Data We Collect


We may collect and process the following types of personal data:

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  • Identity and Contact Data: Name, email address, phone number or other details you provide when contacting us via forms, email, or phone.

  • Safeguarding-Related Data: Information provided when reporting safeguarding concerns, such as details about individuals involved (only where necessary and with a legal basis).

  • Body-Worn Video Data: Audio-visual footage captured by our volunteers’ body-worn video devices, which may include images or voices of individuals in public or community settings.

  • Technical Data: IP address, browser type, device information, and browsing behavior collected automatically when you visit our website.

  • Usage Data: Information about how you use our website, such as pages visited and links clicked.

  • Marketing and Communication Data: Your preferences for receiving newsletters or updates (if applicable).​

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We do not collect special categories of personal data (e.g., health, racial or ethnic origins) unless strictly necessary for our safeguarding activities and with your explicit consent or another lawful basis.

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3. How We Collect Your Data


We collect personal data through:

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  • Direct Interactions: When you fill out contact forms, report safeguarding concerns or subscribe to newsletters.

  • Body-Worn Video: Through BWV devices used by our volunteers during safeguarding activities in public or community settings.

  • Automated Technologies: Via cookies and similar technologies when you visit our website (see Section 8: Cookies).

  • Third Parties: From trusted partners or authorities, only where necessary for safeguarding purposes and with a lawful basis.​

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4. How We Use Your Data


We process your personal data for the following purposes, with the corresponding lawful bases under GDPR:

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  • Responding to inquiries or safeguarding reports: Based on our legitimate interests (to provide our services) or legal obligation (for safeguarding duties).

  • Using body-worn video footage: Based on public task or legal obligation to ensure safety and document safeguarding activities.

  • Managing and improving our website: Based on our legitimate interests (to ensure website functionality and security).

  • Sending newsletters or updates: Based on your consent (if you opt in).

  • Complying with legal or regulatory obligations: Based on legal obligation.

  • Protecting vulnerable individuals: Based on public task or legal obligation for safeguarding activities.​

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We will only process your data for the purposes for which it was collected, unless we reasonably consider another purpose compatible with the original purpose and inform you accordingly.

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5. Body-Worn Video (BWV)


Our volunteers use body-worn video devices to enhance safety and document safeguarding activities. BWV footage may capture images, voices, or other personal data of individuals in public or community settings. We use BWV to:

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  • Ensure the safety of our volunteers and the public.

  • Document incidents for safeguarding purposes.

  • Provide evidence to authorities when required by law.​

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How We Manage BWV Data:

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  • Minimization: BWV is only activated when necessary, and we minimize recording of non-relevant individuals or data.

  • Signage and Notification: Where practical, we use signage or verbal notifications to inform individuals that BWV is in use.

  • Access Control: Footage is securely stored and only accessible to authorised personnel for specific purposes (e.g., safeguarding investigations or legal requirements).

  • Retention: BWV footage is retained for a limited period, typically 30 days, unless required for ongoing investigations or legal obligations, after which it is securely deleted.

  • Sharing: Footage may be shared with law enforcement or social services if required for safeguarding or legal purposes, under strict GDPR-compliant conditions.​

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If you are captured in BWV footage, you may exercise your GDPR rights (see Section 10) by contacting us.

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6. Sharing Your Data


We may share your personal data with:

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  • Service Providers: Third parties providing website hosting, analytics, BWV storage, or IT services, acting as data processors under GDPR-compliant agreements.

  • Authorities: Law enforcement, social services, or other agencies where required for safeguarding purposes or by law.

  • Professional Advisors: Legal or auditing services, where necessary.

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We do not sell your data or share it for marketing purposes.

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7. International Data Transfers


If we transfer your data outside the UK or EEA we ensure appropriate safeguards, such as Standard Contractual Clauses or adequacy decisions, to protect your data in compliance with GDPR.

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8. Cookies and Similar Technologies


Our website uses cookies and similar technologies to enhance your experience, analyse usage and improve functionality. A cookie is a small text file stored on your device when you visit our website.

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Types of Cookies We Use:

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  • Essential Cookies: Necessary for the website to function (e.g., navigation, access to secure areas). You cannot opt out of these cookies as they are critical to website operation.

  • Analytics Cookies: Help us understand how visitors use our website (e.g., Google Analytics). These collect anonymous data unless you consent to identifiable data being processed.

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Cookie Management:


When you first visit our website, we display a cookie consent banner allowing you to accept or reject non-essential cookies. You can manage your preferences at any time via [insert link to cookie settings or instructions, e.g., “our Cookie Settings page”]. You can also disable cookies through your browser settings, but this may affect website functionality.

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Third-Party Cookies:


We may use third-party services (e.g., Google Analytics) that set cookies. These services are GDPR-compliant, and we ensure appropriate safeguards are in place. For details, see the third-party providers' privacy policies.

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9. Data Security


We implement appropriate technical and organisational measures to protect your data, including encryption, access controls and secure servers for website data and BWV footage. However, no system is completely secure, and we cannot guarantee absolute security.

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10. Data Retention


We retain your personal data only for as long as necessary to fulfill the purposes for which it was collected, including legal or reporting requirements. For example:

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  • Contact form data: Retained for 12 months unless further action is required.

  • Safeguarding data: Retained as required by law or safeguarding policies.

  • Body-worn video footage: Retained for 30 days unless needed for investigations or legal purposes.

  • Analytics data: Retained for 12 months in anonymized form.

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11. Your Rights


Under GDPR and UK GDPR, you have the following rights regarding your personal data:

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  • Access: Request a copy of your data, including BWV footage where applicable.

  • Rectification: Correct inaccurate data.

  • Erasure: Request deletion of your data (subject to legal obligations).

  • Restriction: Restrict processing in certain circumstances.

  • Objection: Object to processing based on legitimate interests or for marketing.

  • Data Portability: Receive your data in a structured, machine-readable format.

  • Withdraw Consent: Withdraw consent at any time (where processing is based on consent).

  • Complain: Lodge a complaint with the UK Information Commissioner’s Office (ICO) at www.ico.org.uk or 0303 123 1113.

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To exercise these rights, contact us at contact@cheltenhamguardians.org. We will respond within one month, extendable by two months for complex requests.

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12. Third-Party Links


Our website may contain links to third-party websites. We are not responsible for their privacy practices. Please review their privacy policies before providing personal data.

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13. Children’s Privacy


Our website and BWV activities are not intended for children under 16. We do not knowingly collect data from children without parental consent, except where necessary for safeguarding purposes and with a lawful basis.

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14. Changes to This Policy


We may update this Privacy Policy to reflect changes in our practices or legal requirements. We will notify you of significant changes via our website or by email (if applicable). The latest version is always available at www.cheltenhamguardians.org/privacy.

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15. Contact Us


For questions, concerns, or to exercise your rights, please contact:

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